Phoenix Hospital Group understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of all of our clients and will only use personal data in ways that are described here and in a way that is consistent with our obligations and your rights under the law.

We are regulated by General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”)

What Does This Notice Cover?

This Privacy Information explains how we use your personal data: how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data.

We will tell you if providing some personal data is optional, including if we ask for your consent to process it. In all other cases, we need you to provide your personal data so we can provide care and treatment and receive payment for these services.

What is Personal Data?

Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.

Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, medical records including digital and radiology data and reports, correspondence from and to other doctors/healthcare workers/hospitals and other online identifiers.

The personal data that we use is set out in Part 5, below.

What Are My Rights?

The right to be informed about processing of your personal data

The right to have your personal data corrected if it is inaccurate and to have incomplete personal data completed

The right to object to processing of your personal data*

The right to restrict processing of your personal data*

The right to have your personal data erased (the ‘right to be forgotten’)*

The right to request access to your personal data and information about how we process it

The right to move, copy or transfer your personal data (‘data portability’)

*these rights do not apply in all circumstances

You have the right to complain to the Information Commissioner’s Office (ICO) which can be found at https://ico.org.uk/. It has enforcement powers and can investigate compliance with data protection law. Your Personal Data is data which by itself or with other data available to Phoenix Hospital Group can be used to identify you as an individual. Phoenix Hospital Group is the data controller. This privacy notice sets out how Phoenix Hospital Group will use your personal data. You can contact our Data Protection Officer (DPO) via email data.controller@phoenixhospitalgroup.com if you have any questions.

What Personal Data Do We Collect?

Your name, address and contact details, including email address and home and mobile telephone numbers, date of birth and gender

Your previous and current medical health records whether provided by referrers or other third parties

A record of all treatment provided including medical and nursing notes, records of operations, blood tests and radiology

Your financial information if you are a ‘self-pay’ patient or the financial information of the company or individual who is responsible for the payment of invoices/bills relating to your care (e.g. insurer or sponsor)

Information about your nationality and entitlement to treatment in the UK

Information about medical or health conditions, including whether or not you have a disability for which the organisation needs to make reasonable adjustments

Information about medical or health conditions of your family

Information received in response to any surveys or, complaints claims

Phoenix Hospital Group may collect this information in a variety of ways. For example, data might be collected through Registration and Admission forms; from pre-admission forms, online web forms completed by you at the start of your treatment; from correspondence with you; through the Admission and Registration process or through interviews, meetings or other assessments.

In some cases, the organisation may collect personal data about you from third parties, such as insurer providers, referrers, sponsors

How Do You Use My Personal Data?

To support the provision of your healthcare

To decide how best to provide treatment to you

As necessary to support the healthcare contract with you and to allow us to receive full payment for those services

To keep your records up-to-date as necessary for our own legitimate interests or those of other persons and organisations

For good governance, accounting, and managing and auditing our clinical and business operations

To monitor emails, calls, other communications, and activities on Phoenix Hospital Group networks and systems

For market research, analysis and developing statistics for improving clinical performance; and

As necessary to comply with a legal obligation:

When you exercise your rights under Data Protection Laws and make requests

For compliance with legal and regulatory requirements and related disclosures

For establishment and defence of legal rights

For activities relating to the prevention, detection and investigation of crime

If you ask us to disclose your personal data to other people or organisations such as a company handling a claim on your behalf; or otherwise agree to disclosures;

When we process any special categories of personal data about you at your request (e.g. racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, data concerning your health, sex life or sexual orientation).

You are free at any time to change your mind and withdraw your consent. The consequence might be that we cannot continue to provide full healthcare services to you

How Long Will You Keep My Personal Data?

Information will be kept in in accordance with the retention periods outlined in the Information Governance Alliance (IGA) Records Management Code of Practice for Health and Social Care (2016). Information may be held for longer periods where the following apply:

Retention in case of queries. We will retain your personal data as long as necessary to deal with any queries you may have

Retention in case of claims. We will retain your personal data for as long as you might legally bring claims against us

Retention in accordance with legal and regulatory requirements. We will retain your personal data after you have received healthcare services at our facilities based on our legal and regulatory requirements.

How and Where Do You Store or Transfer My Personal Data?

We will only store or transfer your personal data in the UK. This means that it will be fully protected under the GDPR.

Do You Share My Personal Data?

We will not share any of your personal data with any third parties for any purposes except under the following limited circumstances.

Consultants/doctors and other healthcare professionals who provide treatment to you at our facilities

Other healthcare providers where we feel this will enhance the quality of your care

Sub-contractors and other persons who help us to provide healthcare products and services to you

Companies and other persons providing services to you as part of your extended care

Government bodies and agencies in the UK and overseas (e.g. HMRC who may in turn share it with relevant overseas tax authorities and with regulators)

The Information Commissioner’s Office (ICO)

Courts, to comply with legal requirements, and for the administration of justice

In an emergency or to otherwise protect your vital interests

To protect the security or integrity of our business operations and other patients

Payment systems and providers

Anyone else where we have your consent or as required by law

How Can I Access My Personal Data?

If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.

All subject access requests should be made in writing and sent to the email or postal addresses shown.

To make this as easy as possible for you, an Application for Access to Health Records form is available for you to use,Click here to download, this is the easiest way to tell us everything we need to know to respond to your request as quickly as possible.

We will respond to your subject access request within 14 working days and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of progress.

We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.
Information relating to any changes will be made available via email.